Privacy Policy 2019-02-06T14:27:26+00:00


Your privacy is extremely important to us. In the course of providing our services, PEARL STRATEGY & INNOVATION DESIGN INC. may collect Personal Information. We have prepared this policy to inform you about our ongoing commitment to ensuring that the Personal Information obtained during the course of our activities remains accurate and confidential.

What is Personal Information?

We consider “Personal Information” to mean any information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from such information, other than business contact information (e.g. name, title, business address). This Policy does not cover aggregated data from which the identity of an individual cannot be determined. PEARL STRATEGY & INNOVATION DESIGN INC. retains the right to use aggregated data in any way that it determines appropriate.

GDPR and Privacy Shield Notice

Natural persons located in the European Economic Area (“EEA”) should review the General Data Protection Regulation (“GDPR”) and Privacy Shield Notice here.

Why We May Collect Personal Information

PEARL STRATEGY & INNOVATION DESIGN INC.  may use the Personal Information provided verbally or in writing (including via electronic media) by visitors to our Site, those who purchase products or services through the Site, or other third parties, in order to provide e-newsletters, announcements, and invitations to our events, as well as in order to fulfill order requests made for products and services that we offer.  

The amount and type of information that PEARL STRATEGY & INNOVATION DESIGN INC. gathers depends on the nature of the interaction. For example, we ask visitors who sign up for our products and services to provide a first name and email address. Those who engage in transactions with PEARL STRATEGY & INNOVATION DESIGN INC. by purchasing products and services, for example – are asked to provide additional information, including as necessary the personal and financial information required to process those transactions. In each case,PEARL STRATEGY & INNOVATION DESIGN INC.  collects such information only insofar as is necessary or appropriate to fulfill the purpose of the visitor’s interaction with PEARL STRATEGY & INNOVATION DESIGN INC.

How We Collect and Use Personal Information

PEARL STRATEGY & INNOVATION DESIGN INC.  only collects, uses and discloses Personal Information for purposes that would be considered reasonable in the circumstances and only such information as is required for the purposes of providing services or information to users of the Site. We use only fair and lawful methods to collect Personal Information.

Our use of Personal Information is limited to the purposes described in this Policy and PEARL STRATEGY & INNOVATION DESIGN INC.  does not otherwise sell, trade, barter, exchange or disclose for consideration any Personal Information it has obtained. It may, from time to time, send out promotional or other related messages on behalf of a third-party organization with whom it has partnered, without disclosing Personal Information to the third party. These messages will be labelled distinctly as such to distinguish them from other types of e-mail information we may send.

When We May Disclose Your Personal Information

PEARL STRATEGY & INNOVATION DESIGN INC.  may disclose your Personal Information to:

  • Individuals or organizations who are our advisors or service providers; and/or
  • Individuals or organizations involved in maintaining, reviewing and developing our business systems, procedures and infrastructure including testing or upgrading our computer systems

In the event sensitive Personal Information is provided to us, we will not disclose such Personal Information unless it is required in order to provide a user of our Site with our services.

Where PEARL STRATEGY & INNOVATION DESIGN INC. discloses Personal Information to organizations that perform services on its behalf, we will require those service providers to use such information solely for the purposes of providing services to our Go site users or the person concerned and to have appropriate safeguards for the protection of that Personal Information.

Please note that there are circumstances where the use and/or disclosure of Personal Information may be justified or permitted or where PEARL STRATEGY & INNOVATION DESIGN INC.  is obliged to disclose information without consent. Such circumstances may include:

  • Where required by law or by order or requirement of a court, administrative agency or governmental tribunal;
  • Where PEARL STRATEGY & INNOVATION DESIGN INC. . believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
  • Where it is necessary to establish or collect monies owing to PEARL STRATEGY & INNOVATION DESIGN INC.
  • Where it is necessary to permit PEARL STRATEGY & INNOVATION DESIGN INC. to pursue available remedies or limit any damages that we may sustain; or
  • Where the information is public.

Where obliged or permitted to disclose information without consent,PEARL STRATEGY & INNOVATION DESIGN INC.  will not disclose more information than is required.


Unless permitted by law, no Personal Information is collected, without first obtaining the consent of the individual concerned to the collection, use and dissemination of that information. However, we may seek consent to use and disclose Personal Information after it has been collected in those cases where PEARL STRATEGY & INNOVATION DESIGN INC.  wishes to use the information for a purpose not identified in this Policy or not previously identified or for which the individual concerned has not previously consented.

We comply with all Canadian and international SPAM laws with respect to the collection and use of Personal Information over the Web.

By providing Personal Information to PEARL STRATEGY & INNOVATION DESIGN INC.  you agree and consent that we may collect, use and disclose your Personal Information in accordance with this Policy. In addition, where appropriate, specific authorizations or consents may be obtained from time to time.

In most cases and subject to legal and contractual restrictions, you are free to refuse or withdraw your consent at any time upon reasonable, advance notice. It should be noted that in certain circumstances, certain services can only be offered if you provide Personal Information toPEARL STRATEGY & INNOVATION DESIGN INC.  Consequently, if you choose not provide us with any required Personal Information, we may not be able to offer you the services requested. We will inform you of the consequences of the withdrawal of consent.

The Accuracy and Retention of Personal Information

PEARL STRATEGY & INNOVATION DESIGN INC. endeavours to ensure that any Personal Information provided and in its possession is as accurate, current and complete as necessary for the purposes for which we use that information. If we become aware that Personal Information is inaccurate, incomplete or out of date, we will revise the Personal Information and, if necessary, use its best efforts to inform third parties which were provided with inaccurate information so that those third parties may also correct their records.

We keep your Personal Information only as long as it is required for the reasons it was collected. The length of time we retain information varies, depending on the service and the nature of the information. This period may extend beyond the end of a person’s relationship with us but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date.

When your Personal Information is no longer required, we have procedures to destroy, delete, erase or convert it into an anonymous form.

Currently, the principal places in which PEARL STRATEGY & INNOVATION DESIGN INC. holds personal information are in the city of Toronto, Ontario, Canada.

Protection of Personal Information

PEARL STRATEGY & INNOVATION DESIGN INC.  endeavours to maintain appropriate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information. This also applies to our disposal or destruction of Personal Information.

PEARL STRATEGY & INNOVATION DESIGN INC. further protects Personal Information by restricting access to it to those employees that the management of PEARL STRATEGY & INNOVATION DESIGN INC. has determined need to know that information in order that we may provide our products, services or information.

If any employee of PEARL STRATEGY & INNOVATION DESIGN INC.  misuses Personal Information, this will be considered as a serious offence for which disciplinary action may be taken, up to and including termination of employment. If any individual or organization misuses Personal Information – provided for the purpose of providing services to or for PEARL STRATEGY & INNOVATION DESIGN INC.  this will be considered a serious issue for which action may be taken, up to and including termination of any agreement between PEARL STRATEGY & INNOVATION DESIGN INC.  and that individual or organization.

Access to Your Personal Information

PEARL STRATEGY & INNOVATION DESIGN INC.  permits the reasonable right of access and review of Personal Information held by us about an individual and will endeavour to provide the information in question within a reasonable time, generally no later than 30 days following the request.

We will provide information from our records in a form that is easy to understand. We reserve the right not to change any Personal Information but will append any alternative text the individual concerned believes to be appropriate.

PEARL STRATEGY & INNOVATION DESIGN INC. reserves the right to decline to provide access to Personal Information where the information requested:

  • Would disclose (i) Personal Information, including opinions, about another individual or about a deceased individual; or (ii) trade secrets or other business confidential information that may harm PEARL STRATEGY & INNOVATION DESIGN INC.  or the competitive position of a third party;
  • Would interfere with contractual or other negotiations of PEARL STRATEGY & INNOVATION DESIGN INC. or a third party;
  • Is subject to solicitor-client, litigation or other legal privilege;
  • Is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information;
  • Does not exist, is not held, or cannot be found by PEARL STRATEGY & INNOVATION DESIGN INC.
  • Could reasonably result in (i) serious harm to the treatment or recovery of the individual concerned, (ii) serious emotional harm to the individual concerned or another individual, or (iii) serious bodily harm to another individual;
  • May harm or interfere with law enforcement activities and other investigative or regulatory functions  of a body authorized by law to perform such functions; or
  • May be withheld or is requested to be withheld under applicable legislation.

Where information will not or cannot be disclosed, the individual making the request will be provided with the reasons for non-disclosure.


Our Web servers track general information about visitors such as their domain name, time of visit and which pages are being accessed. This information is used internally, only in aggregate form, to better serve visitors by helping us to:

  • Manage our site;
  • Diagnose any technical problems; and
  • Improve the content of our Website.

For each visitor to our Web page, our Web server automatically recognizes only the visitor’s IP address, but not their e-mail address.

In browsing the Web, you will encounter a technology known as “cookies.” A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. PEARL STRATEGY & INNOVATION DESIGN INC.  uses cookies to help us identify and track visitors, their usage of the Website, and their Website access preferences. PEARL STRATEGY & INNOVATION DESIGN INC.  visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using our Websites, with the drawback that certain features of PEARL STRATEGY & INNOVATION DESIGN INC.  Websites may not function properly without the aid of cookies.

We do not partner with or have special relationships with any ad server companies.

We have no control over the content of third party Websites that individuals may access through hyperlinks at our Website. We encourage everyone to read the privacy policy of every Website they visit.

Modifications to our Privacy Policy

From time to time, we may use our site users’ information for new, unanticipated uses not previously disclosed in our Privacy Policy. If our information practices change in the future, we will post these policy changes to this page of our website. If you have any concerns, please review our Privacy Policy periodically.

Resolving Your Privacy Concerns

In the event of questions about: (i) access to your Personal Information; (ii) our collection, use, management or disclosure of Personal Information; or (iii) this Policy; please contact our privacy officer by sending an e-mail to SUSANWEAVER@PEARL-STRATEGY.CA the PEARL STRATEGY & INNOVATION DESIGN INC.  Privacy Officer.

PEARL STRATEGY & INNOVATION DESIGN INC.  will investigate all complaints and if a complaint is justified, we will take all reasonable steps to resolve the issue.